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Union Calendar No. 721


114TH CONGRESS REPORT
" HOUSE OF REPRESENTATIVES !
2d Session 114910

SUMMARY OF ACTIVITIES
ONE HUNDRED FOURTEENTH CONGRESS

A REPORT

OF THE

COMMITTEE ON ETHICS
HOUSE OF REPRESENTATIVES

JANUARY 3, 2017.Committed to the Committee of the Whole House on


the State of the Union and ordered to be printed
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U.S. GOVERNMENT PUBLISHING OFFICE


23224 WASHINGTON : 2017
E:\Seals\Congress.#13

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COMMITTEE ON ETHICS
CHARLES W. DENT, Pennsylvania LINDA T. SA NCHEZ, California
Chairman Ranking Member
PATRICK MEEHAN, Pennsylvania MICHAEL E. CAPUANO, Massachusetts
TREY GOWDY, South Carolina YVETTE D. CLARKE, New York
SUSAN W. BROOKS, Indiana TED DEUTCH, Florida
KENNY MARCHANT, Texas JOHN B. LARSON, Connecticut

REPORT STAFF
THOMAS A. RUST, Chief Counsel/Staff Director
PATRICK MCMULLEN, Director of Investigations
TONIA SMITH, Director of Advice and Education
CLIFFORD C. STODDARD, Counsel to the Chairman
DANIEL J. TAYLOR, Counsel to the Ranking Member
MOLLY MCCARTY, Investigator
DESTINAE DEMERY, Financial Disclosure Clerk
CHRISTIAN HOLLOWELL, Advice and Education Clerk
MICHAEL KOREN, Investigative Clerk
TAMAR NEDZAR, Senior Counsel
DAVID ARROJO, Counsel
KATHRYN LEFEBER DONAHUE, Counsel
NADIA KONSTANTINOVA, Counsel
BRITTNEY PESCATORE, Counsel
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(II)

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LETTER OF SUBMITTAL

HOUSE REPRESENTATIVES,
OF
COMMITTEE ON ETHICS,
Washington, DC, January 2, 2017.
Hon. KAREN L. HAAS,
Clerk, House of Representatives,
Washington, DC.
DEAR MS. HAAS: Pursuant to clauses 3(a)(2) and 3(b) of Rule XI
of the Rules of the House of Representatives, we herewith transmit
the attached Report, Summary of Activities 114th Congress.
Sincerely,
CHARLES W. DENT,
Chairman.
LINDA T. SA NCHEZ,
Ranking Member.

(III)
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CONTENTS

I. INTRODUCTION .......................................................................................... 3
II. ADVICE AND EDUCATION ........................................................................ 3
III. FINANCIAL DISCLOSURE ......................................................................... 10
IV. COMMITTEE RULES ................................................................................... 12
V. INVESTIGATIONS ........................................................................................ 12
APPENDIX I: RELEVANT HOUSE RULES ........................................................ 31
APPENDIX II: ADVISORY MEMORANDA .......................................................... 42
APPENDIX III: COMMITTEE RULES ................................................................. 134
APPENDIX IV: PUBLIC STATEMENTS .............................................................. 187
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(V)

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Union Calendar No. 721
114TH CONGRESS REPORT
" HOUSE OF REPRESENTATIVES !
2d Session 114910

SUMMARY OF ACTIVITIES
ONE HUNDRED FOURTEENTH CONGRESS

JANUARY 3, 2017.Committed to the Whole House on the State of the Union and
ordered to be printed

Mr. DENT and Ms. SA NCHEZ, from the Committee on Ethics,


submitted the following

R E P O R T
OVERVIEW
The Committee on Ethics (Committee) is tasked with inter-
preting and enforcing the Houses ethics rules. The Committee has
sole jurisdiction over the interpretation of the Code of Official Con-
duct, which governs the acts of House Members, officers, and em-
ployees. The Committee is the only standing House committee with
equal numbers of Democratic and Republican Members. The opera-
tive staff of the Committee is required by rule to be professional
and nonpartisan.
In the 114th Congress, the Committee was led by Chairman
Charles W. Dent and Ranking Member Linda T. Sanchez. The
Members appointed at the beginning of the Congress were Patrick
Meehan, Michael E. Capuano, Trey Gowdy, Yvette Clarke, Susan
W. Brooks, Ted Deutch, Kenny Marchant, and John B. Larson.
The Committees core responsibilities include providing training,
advice, and education to House Members, officers, and employees;
reviewing and approving requests to accept privately-sponsored
travel related to official duties; reviewing and certifying all finan-
cial disclosure reports Members, candidates for the House, officers,
and senior staff are required to file; and investigating and adjudi-
cating allegations of misconduct and violations of rules, laws, or
other standards of conduct.
The Committee met 24 times in the 114th Congress, including 12
times in 2015, and 12 times in 2016.
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Within the scope of its training, advice and education, travel, and
financial disclosure responsibilities, the Committee:

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Issued more than 850 formal advisory opinions regarding


ethics rules;
Reviewed and approved nearly 3,900 requests to accept
privately-sponsored, officially-connected travel;
Fielded nearly 55,000 informal telephone calls, emails, and
in-person requests for guidance on ethics issues;
Released 14 advisory memoranda on various ethics topics
to the House;
Provided training to approximately 11,000 House Mem-
bers, officers, and employees each year, and reviewed their cer-
tifications for satisfying the Houses mandatory training re-
quirements;
Received nearly 16,000 Financial Disclosure Statements
and amendments filed by House Members, officers, senior staff,
and House candidates; and
Received more than 3,000 Periodic Transaction Reports
filed by House Members, officers, and senior staff, containing
thousands of transactions.
In addition, the Committee actively investigates allegations
against House Members, officers, and employees, using a mix of in-
vestigative techniques to determine the validity of factual allega-
tions, explore potential rules violations, and recommend appro-
priate sanctions and corrective actions. The Committees options for
investigating a matter include fact-gathering under Committee
Rule 18(a), the empanelment of investigative subcommittees (ISCs),
consideration of formal complaints, and the review of transmittals
from the Office of Congressional Ethics (OCE). Committee review
of a matter in any of these formats is an investigation under
House and Committee rules. Also, it is not uncommon for a matter
to be investigated by the Committee in more than one of these for-
mats over the course of the Committees overall review of that mat-
ter. For example, as discussed further in this report, from time to
time the Committee may begin an investigation under Committee
Rule 18(a) and subsequently determine that it is appropriate to
continue the investigation through an investigative subcommittee.
The initiation or status of an investigative matter may or may
not be publicly disclosed, depending on the circumstances of the in-
dividual matter. However, the fact that the Committee is inves-
tigating a particular matter, opts to investigate a matter in one for-
mat instead of another, is required or chooses to make a public
statement regarding a pending investigative matter, or that a
House Member, officer, or employee is referenced in an investiga-
tive matter should not be construed as a finding or suggestion that
the Member, officer, or employee has committed any violation of
the rules, law, or standards of conduct.
During the 114th Congress, within the scope of its investigative
responsibilities, the Committee:
Commenced or continued investigative fact-gathering re-
garding 78 separate investigative matters;
Empanelled four new investigative subcommittees, in the
matters of Representative Ed Whitfield, Representative Chaka
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Fattah, Representative Robert Pittenger, and Representative


Corrine Brown;
Held 11 investigative subcommittee meetings;

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Filed 5 reports with the House totaling nearly 2,100 pages


regarding various investigative matters;
Publicly addressed 23 matters, described in Section V of
this report;
Resolved 40 additional matters;
Conducted 93 voluntary witness interviews;
Authorized the issuance of 31 subpoenas; and
Reviewed nearly 600,000 pages of documents.
All votes taken in the investigative subcommittees were unani-
mous. There were a total of 17 investigative matters pending before
the Committee as of January 2, 2017.
All of the Committees work as summarized in this report is
made possible by the Committees talented professional, non-
partisan staff. The Members of the Committee wish to acknowledge
their hard work and dedication to the Committee and the House.
In particular, the Committee wishes to acknowledge the service
and career of Joanne White, who retired in 2016 following more
than 41 years of service to the House, including more than 25 years
on the Committees staff.1
I. INTRODUCTION
House Rule XI, clause 1(d), requires each committee to submit to
the House, not later than January 2 of each odd-numbered year,
a report on the activities of that committee under that rule and
House Rule X. This report summarizes the activities of the Com-
mittee for the entirety of the 114th Congress.
The jurisdiction of the Committee on Ethics is defined in clauses
1(g) and 11(g)(4) of House Rule X, clause 3 of House Rule XI, and
clause 5(h) of House Rule XXV. The text of those provisions is at-
tached as Appendix I to this Report.
In addition, a number of provisions of statutory law confer au-
thority on the Committee. Specifically, for purposes of the statutes
on gifts to federal employees (5 U.S.C. 7353) and gifts to superiors
(5 U.S.C. 7351), both the Committee and the House of Represent-
atives are the supervising ethics office of House Members, offi-
cers, and employees. In addition, as discussed further in Part III
below, for House Members, officers, and employees, the Committee
is both the supervising ethics office with regard to financial dis-
closure under the Ethics in Government Act (EIGA) (5 U.S.C. app.
101 et seq.) and the employing agency for certain purposes
under the Foreign Gifts and Decorations Act (5 U.S.C. 7342). The
outside employment and earned income limitations of the EIGA are
administered by the Committee with respect to House Members, of-
ficers, and employees (5 U.S.C. app. 503(1)(A)). Finally, the notifi-
cation of negotiation and recusal requirements created by the Hon-
est Leadership and Open Government Act (HLOGA) are adminis-
tered, in part, by the Committee.
II. ADVICE AND EDUCATION
Pursuant to a provision of the Ethics Reform Act of 1989 (2
U.S.C. 4711(i)), the Committee maintains an Office of Advice and
Education, which is staffed as directed by the Committees Chair-
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1 See 162 Cong. Rec. E1262, E1263 & E1255 (daily ed. Sep. 13, 2016) (statements of Chairman
Dent, Ranking Member Sanchez, and former Chairman Conaway).

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man and Ranking Member. Under the statute, the primary respon-
sibilities of the Office include the following:
Providing information and guidance to House Members, of-
ficers, and employees on the laws, rules, and other standards
of conduct applicable to them in their official capacities;
Drafting responses to specific advisory opinion requests re-
ceived from House Members, officers, and employees, and sub-
mitting them to the Chairman and Ranking Member for review
and approval;
Drafting advisory memoranda on the ethics rules for gen-
eral distribution to House Members, officers, and employees,
and submitting them to the Chairman and Ranking Member,
or the full Committee, for review and approval; and
Developing and conducting educational briefings for House
Members, officers, and employees.
The duties of the Office of Advice and Education are also ad-
dressed in Committee Rule 3, which sets out additional require-
ments and procedures for the issuance of Committee advisory opin-
ions.
Under Committee Rule 3(j), the Committee will keep confidential
any request for advice from a Member, officer, or employee, as well
as any response to such a request. As a further inducement to
House Members, officers, and employees to seek Committee advice
whenever they have any uncertainty on the applicable laws, rules,
or standards, statutory law (2 U.S.C. 4711(i)(4)) provides that no
information provided to the Committee by a Member or staff per-
son when seeking advice on prospective conduct may be used as a
basis for initiating a Committee investigation if the individual acts
in accordance with the Committees written advice. In the same
vein, Committee Rule 3(k) provides that the Committee may take
no adverse action in regard to any conduct that has been under-
taken in reliance on a written opinion of the Committee if the con-
duct conforms to the specific facts addressed in the opinion. Com-
mittee Rule 3(l) also precludes the Committee from using informa-
tion provided to the Committee by a requesting individual seeking
advice regarding prospective conduct . . . as the basis for initiating
an investigation, provided that the requesting individual acts in
good faith in accordance with the written advice of the Committee.
In addition, the Committee understands that federal courts may
consider the good faith reliance of a House Member, officer, or em-
ployee on written Committee advice as a defense to Justice Depart-
ment prosecution regarding certain statutory violations.2
The Committee believes that a broad, active program for advice
and education is an extremely important means for attaining un-
derstanding of, and compliance with, the ethics rules. The specifics
of the Committees efforts in the areas of publications, briefings,
and advisory opinion letters during the 114th Congress are set
forth below. In addition, on a daily basis Committee staff attorneys
provided informal advice in response to inquiries received from
Members, staff persons, and third parties in telephone calls and e-
2 For example, a federal court held that it is a complete defense to a prosecution for conduct
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assertedly in violation of a related federal criminal strict-liability statute (18 U.S.C. 208) that
the conduct was undertaken in good faith reliance upon erroneous legal advice received from
the officials supervising ethics office. United States v. Hedges, 912 F.2d 1397, 1403 n.2 (11th
Cir. 1990).

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mails directed to the Committee office, as well as in person. During


the 114th Congress, Committee attorneys responded to nearly
55,000 phone calls and e-mail messages seeking advice, and partici-
pated in many informal meetings with Members, House staff, or
outside individuals or groups regarding specific ethics matters.
PUBLICATIONS

The Committees major publication is the House Ethics Manual,


an updated version of which was issued in March 2008. The Man-
ual provides detailed explanations of all aspects of the ethics rules
and statutes applicable to House Members, officers, and employees.
Topics covered by the Manual include the acceptance of gifts or
travel, campaign activity, casework, outside employment, and in-
volvement with official and outside organizations. The House Ethics
Manual is posted in a searchable format on the Committees Web
site: https://ethics.house.gov.
The Committee updates and expands upon the materials in the
Manual, as well as highlights matters of particular concern,
through the issuance of general advisory memoranda to all House
Members, officers, and employees. The memoranda issued during
the 114th Congress were as follows:
The 2015 Outside Earned Income Limit and Salaries Trig-
gering the Financial Disclosure Requirement and Post-Employ-
ment Restrictions Applicable to House Officers and Employees
(January 21, 2015);
Upcoming Financial Disclosure Clinics & Training (April
17, 2015);
Reminder about Annual Ethics Training Requirements for
2015 (November 24, 2015);
Holiday Guidance on the Gift Rule (December 7, 2015);
The 2016 Outside Earned Income Limit and Salaries Trig-
gering the Financial Disclosure Requirement and Post-Employ-
ment Restrictions Applicable to House Officers and Employees
(January 5, 2016);
Upcoming Financial Disclosure Clinics & Training (April
15, 2016);
Member Participation in Certain Events Taking Place
During a National Political Convention (May 13, 2016);
Gift Rules Applicable to National Political Conventions
(June 10, 2016);
Reminder about Annual Ethics Training Requirements for
2016 (September 20, 2016);
Member Swearing-in and Inauguration Day Receptions,
and Attendance at Inaugural-Related Events (November 29,
2016);
Guidance on House Staff Assisting in the Presidential
Transition (December 5, 2016);
Holiday Guidance on the Gift Rule (December 5, 2016);
Negotiations for Future Employment and Restrictions on
Post-Employment for House Members and Officers (December
22, 2016); and
Negotiations for Future Employment and Restrictions on
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Post-Employment for House Staff (December 22, 2016).


A copy of each of these advisory memoranda is included as Ap-
pendix II to this Report. In addition, these memoranda are avail-

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able to the House and the public on the Committees Web site:
https://ethics.house.gov.
In addition to the advisory memoranda listed above, the Com-
mittee joined a new initiative with the Committee on House Ad-
ministration to issue periodic joint guidance from the two commit-
tees on issues of overlapping jurisdiction. The Committee also
issued an updated version of its summary memorandum, High-
lights of the House Ethics Rules, in May 2015. Copies of all current
Committee publications are available from the Committees office,
and their text is posted on the Committees Web site. The Com-
mittee also submits a report each month of the Committees activi-
ties to the Committee on House Administration. Finally, with this
report, the Committee has sought to provide as much transparency
as is appropriate. In addition to the many numbers referred to
throughout this report, the Committee annually publishes the fol-
lowing summary chart in the interest of transparency.
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ETHICS TRAINING

Clause 3(a)(6) of House Rule XI, which originated in the 110th


Congress, requires each House employee to complete ethics train-
ing each calendar year, pursuant to guidelines to be issued by the
Committee. The House rules and Committees guidelines require
each House employee to complete one hour of ethics training each
calendar year. The guidelines also require all House employees who
are paid at the senior staff rate to complete an additional hour
of training once each Congress on issues primarily of interest to
senior staff.3 Rule XI requires new House Members and employees
to complete ethics training within 60 days of the commencement of
their service to the House.4
Pursuant to its obligations under Rule XI, the Committee held
104 ethics training sessions during 2015 and 64 during 2016. Dur-
ing the 114th Congress, all employees other than new employees
were permitted to fulfill their training requirement either through
attending a training session in person or by viewing an on-line
presentation. The training sessions for new employees provided a
general summary of the House ethics rules in all areas, such as
gifts, travel, campaign activity, casework, involvement with outside
entities, and outside employment. The live and on-line sessions for
existing House employees covered specific topics, such as gifts and
travel or campaign work, on a more in-depth basis. The Committee
also had several different options that senior staff could use to ful-
fill their requirement of one additional hour of training. The on-line
training provided a general overview of ethics rules of particular
interest to senior staff. The live training sessions focused in depth
on a single topic, of import for senior staff.
In 2015, the Committee trained more than 2,000 employees in
person at live ethics briefings, and nearly 8,000 used one of the on-
line training options. During 2016, the Committee trained more
than 2,200 employees in person at live ethics briefings, and nearly
9,000 through one of the on-line training options. The total number
of employees who completed ethics training for 2016 will be deter-
mined after January 31, 2017, the date that House Rule XI estab-
lished as the deadline for employees to certify completion of the
ethics training requirement for 2016.
In addition to the training required under House Rule XI, the
Committee also provided training in several other contexts. The
House will include 52 new Members in the 115th Congress, most
of whom have not previously served in the House. The Committee
made a presentation to the Members-elect of the 115th Congress
during New Member Orientation. The Committee also met with nu-
merous departing Members and staff to counsel them on the ethics
rules related to their transition to private life and the post-employ-
ment restrictions. The Committee also provided training open to all
House Members, officers, and employees on the financial disclosure
rules, which are discussed further in Section III. Finally, together
with the Committee on House Administration, the Committee par-
3 In 2016, the senior staff rate was $123,175 per year, or a monthly salary above $10,265. This
figure is subject to change each year, and the Committee issues a general advisory memo-
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randum to all House Members, officers, and employees announcing changes in this and other
salary thresholds relevant to ethics rules.
4 The requirement that new Members receive training within 60 days of commencement of
their service to the House was added to House Rule XI in the 114th Congress.

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ticipated in two general briefings, one in 2015 and one in 2016, on


the rules related to Member participation in the Congressional Art
Competition.
Committee staff also participated in approximately 10 briefings
sponsored by or held for the members of outside organizations. In
addition, Committee staff led approximately 12 briefings for vis-
iting international dignitaries from a variety of countries, including
Colombia, Kosovo, and Malawi.
The Committee will continue this outreach activity in the 115th
Congress.
ADVISORY OPINION LETTERS

The Committees Office of Advice and Education, under the direc-


tion and supervision of the Committees Chairman and Ranking
Member, prepared and issued nearly 900 private advisory opinions
during the 114th Congress: 498 in 2015 and 360 in 2016. Opinions
issued by the Committee in the 114th Congress addressed a wide
range of subjects, including various provisions of the gift rule,
Member or staff participation in fund-raising activities of charities
and for other purposes, the outside earned income and employment
limitations, campaign activity by staff, and the post-employment
restrictions.
TRAVEL APPROVAL LETTERS

As discussed above, House Rule XXV, clause 5(d)(2), which was


enacted at the start of the 110th Congress, charged each House
Member or employee with obtaining approval of the Committee
prior to undertaking any travel paid for by a private source on
matters connected to the individuals House duties.
House Rule XXV, clause 5(i), charges the Committee with under-
taking an annual review of its guidelines and regulations regarding
privately-funded, officially-connected travel by House Members, of-
ficers, and employees. In the 112th Congress, the Committee car-
ried over a bipartisan travel working group to assess and make rec-
ommendations regarding its process for the review and approval of
such travel. Committee members Representatives Charles Dent
and Donna F. Edwards comprised the working group. As a result
of the efforts of the working group, the Committee adopted com-
prehensive revised travel regulations for privately-sponsored, offi-
cially-connected travel which were released as a general advisory
on December 27, 2012. The regulations were made effective for
travel beginning on April 1, 2013. The regulations are available to
the House and the public on the Committees Web site.5 In the
114th Congress, the Committee continued its ongoing efforts to re-
view the guidelines and regulations regarding privately-funded, of-
ficially-connected travel. This review included a thorough examina-
tion of the forms used for privately-funded, officially-connected
travel approval.
In general, the Committee requires that any House Member, offi-
cer, or employee who wishes to accept an offer of privately-spon-
sored, officially-connected travel must submit all required paper-
work to the Committee at least 30 days prior to the start of the
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5 House Comm. on Ethics, Travel Guidelines and Regulations (Travel Regulations) (Dec. 27,
2012), available at https://ethics.house.gov/sites/ethics.house.gov/files/travel%20regsl0.pdf.

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trip.6 However, the 30-day requirement does not apply to certain


types of trips, and the Committee retains authority to approve re-
quests submitted after that deadline in exceptional circumstances.7
When the Committee opts to approve a request filed after the gen-
eral deadline, the approval letter sent to the travelerwhich must
ultimately be publicly disclosednotes that fact.
Under the travel approval process established by the Committee
to implement this rule, the Committee reviewed more than 2,400
requests to accept privately-sponsored, officially-connected travel,
and issued letters approving more than 2,000 such requests in
2015. In 2016, the Committee reviewed nearly 2,000 requests to ac-
cept privately-sponsored, officially-connected travel, and issued let-
ters approving more than 1,800 such requests.
House Rules and the Committees Travel Regulations require all
House Members, officers, and employees who receive Committee
approval to accept privately-sponsored, officially-connected travel to
file detailed paperwork about the trip with the Clerk within 15
days of the conclusion of the trip.8 The Committee also reviewed
the post-travel disclosure forms filed by the traveler for each ap-
proved trip and requested amendments or other remedial action by
the traveler when deemed necessary.9
The post-travel filings are made available to the public in a
searchable online database on the Clerks Web site, at http://
clerk.house.gov/public_disc/giftTravel-search.aspx. The public, the
media, and outside groups have used this valuable resource for
years, and the Committee anticipates that they will continue to do
so. The Committee requires those Members, officers, and employees
who are required to file financial disclosure statements, as dis-
cussed in Section III, to also provide information about privately-
sponsored, officially-connected travel on their financial disclosure
filings, but the public should be aware that much more detailed
and timely public filings regarding such travel are required, and
the most authoritative source of those filings is the Clerks Web
site.
III. FINANCIAL DISCLOSURE
Title I of the Ethics in Government Act of 1978 (EIGA), as
amended (5 U.S.C. app. 101111), requires certain officials in all
branches of the federal government, as well as candidates for fed-
eral office, to file publicly-available Financial Disclosure State-
ments (Statements). These Statements disclose information con-
cerning the filers finances, as well as those of certain family mem-
bers. By May 15 of each year, these covered individuals are re-
quired to file a Statement that provides information for the pre-
ceding calendar year. In addition, the Stop Trading on Congres-
sional Knowledge Act (STOCK Act) amended EIGA in 2012 to add
a requirement that financial disclosure filers must report certain
securities transactions over $1,000 no later than 45 days after the
6 Id. at Part 500Committee Approval Process.
7 Id. at 501.1.
8 House Rule XXV, clause 5(b)(1)(A)(ii); Travel Regulations at Part 600Post-Travel Disclo-
sure.
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9 From time to time, a traveler may inadvertently fail to file all of the required paperwork
with their post-travel submission. That is not an indication that the information was not pro-
vided to the Committee prior to the trip and before the Committee approved the request, only
that the travelers subsequent submission was incomplete.

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transaction. The Committee has termed these interim reports


Periodic Transaction Reports or PTRs.
Financial disclosure filings are not intended to be net worth
statements, nor are they well suited to that purpose. As the Com-
mission on Administrative Review of the 95th Congress stated in
recommending broader financial disclosure requirements: The ob-
jectives of financial disclosure are to inform the public about the
financial interests of government officials in order to increase pub-
lic confidence in the integrity of government and to deter potential
conflicts of interest. 10
All Members of the House, including Members who are serving
the first year of their first term, are required to file a Statement.
In addition, any officer or employee of the House who was paid at
or above 120 percent of the minimum pay for Executive Branch
GS15 (the senior staff rate) for at least 60 days in a calendar
year must file a Statement on or before May 15 of the following
year. Certain other employees, including those designated by a
Member as a principal assistant for financial disclosure purposes
and employees who are shared staff of three or more offices, are
also subject to some financial disclosure filing requirements.
Starting in 2013, financial disclosure filers were able to use an
online electronic filing system to draft and submit their Statements
and PTRs. Thanks to a very industrious collaboration with the
Clerk of the House to create the online system, and extensive out-
reach and education, more than half of all Members and staff used
the online electronic filing system to submit their calendar year
2016 Statements. Specifically, 63% of Members and 72% of House
staff used the online system to draft and submit their 2016 State-
ments.
The Committee engages in substantial training efforts to assist
filers with completing their Statements and PTRs. The Committee
held three briefings for Members, officers, and employees. The
Committee hosted seven walk-in clinics to support filers use of the
electronic filing system for Statements and PTRs.
For the 114th Congress, the Committee continued its long-stand-
ing practice of Committee staff meeting with Members, officers,
and employees of the House to assist filers with their Statements
and PTRs. Committee staff responded to telephone, e-mail, and in-
person questions from filers on an as-needed basis, in addition to
reviewing drafts of Statements and PTRs. The Committee encour-
ages all financial disclosure filers to avail themselves of opportuni-
ties to seek and receive information and assistance.
For calendar year 2015, the Legislative Resource Center of the
Clerks office referred a total of 3,516 Financial Disclosure State-
ments to the Committee for review. Of those, 3,177 were State-
ments filed by current or new House Members or employees, and
339 were Statements filed by candidates for the House. The Clerks
office also referred a total of 1,193 PTRs to the Committee for re-
view. The Committee received 554 PTRs from Members and 639
PTRs from officers and employees.
For calendar year 2016, the Legislative Resource Center of the
Clerks office referred a total of 4,597 Statements to the Committee
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10 House Commn on Admin. Review, Financial Ethics, H. Doc. 9573, 96th Cong., 1st Sess.
6 (1977).

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for review. Of those, 3,777 were Statements filed by current or new


House Members or employees, and 820 were Statements filed by
candidates for the House. The Clerks office also referred a total of
2,016 PTRs to the Committee for review. The Committee received
818 PTRs from Members and 1198 PTRs from officers and employ-
ees.
Where the Committees review indicated that a filed Statement
or PTR was deficient, the Committee requested an amendment
from the filer. Such amendments are routine and, without evidence
of a knowing or willful violation, the Committee will usually take
no further action after the amendment has been filed. Amendments
are made publicly available in the same manner as other financial
disclosure filings. The Committee also followed up with filers whose
Statements indicated non-compliance with applicable law, such as
the outside employment and outside earned income limitations.
More information about financial disclosure, including the Com-
mittees instruction booklet for filers and blank copies of Statement
and PTR forms, is available on the Committees Web site, at
https://ethics.house.gov/financial-dislosure. In addition, financial
disclosure filings of Members and candidates and other information
about financial disclosure is available on the Clerks Web site, at
http://clerk.house.gov/public_disc/financial.aspx.
IV. COMMITTEE RULES
After the beginning of each Congress, the Committee must adopt
rules for that Congress. On February 12, 2015, the Committee met
and adopted the Committee rules for the 114th Congress. The sub-
stance of the Committee rules for the 114th Congress was largely
identical to the amended rules adopted in the 113th Congress.11
A copy of the Committee Rules for the 114th Congress is in-
cluded as Appendix III to this Report.
V. INVESTIGATIONS
Article I, Section 5 of the Constitution grants each chamber of
Congress the power to punish its Members for disorderly Behav-
iour, and, with the Concurrence of two thirds, expel a Member.
The Committee is designated by House rule as the body which con-
ducts the investigative and adjudicatory functions which usually
precede a vote by the full House regarding such punishment or ex-
pulsion. House Rule XI, clause 3, as well as Committee Rules 13
through 28, describe specific guidelines and procedures for the ex-
ercise of that authority.
The Committees investigations are conducted either pursuant to
authorization by the Chairman and Ranking Member, under Com-
mittee Rule 18(a), or pursuant to a vote by the Committee to
empanel an Investigative Subcommittee (ISC). Most investigations
are conducted pursuant to Committee Rule 18(a). Even those inves-
tigations that ultimately result in the formation of an ISC usually
begin as Committee Rule 18(a) investigations. Committee Rule
18(a) and ISC investigations differ only in process, not substance.
11 In the 112th Congress, as a result of the efforts of a working group formed to assess the
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Committees rules and procedures, numerous changes were made to the Committees investiga-
tive rules, including changes to Committee Rules 4, 9, 17A, 18, 19 and 23. Those changes were
adopted by the Committee on May 18, 2012. House Comm. on Ethics, Summary of Activities
One Hundred Twelfth Congress, H. Rept. 112730, 112th Cong. 2nd Sess. at 21 (2012).

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In both kinds of investigations, Committee staff is authorized by


Members of the Committee to interview witnesses, request docu-
ments and information, and engage in other investigative actions.
Further, both the Committee and ISC may authorize subpoenas for
documents and witness testimony.12 Members of the Committee
can, and do, attend and participate in voluntary interviews with
witnesses in both 18(a) and ISC investigations. House and Com-
mittee Rules require attendance of Members at interviews con-
ducted pursuant to subpoena in both 18(a) and ISC investigations.
The Committee may opt to investigate a matter under Com-
mittee Rule 18(a) rather than an ISC for a number of reasons. For
example, investigating pursuant to Committee Rule 18(a) preserves
the Committees ability both to deploy its limited resources in the
most efficient manner possible, and to maintain the confidentiality
of its investigations. In general, the Committee publicly announces
when it has voted to empanel an ISC. In contrast, most investiga-
tions conducted pursuant to Committee Rule 18(a) are confidential.
Maintaining the confidentiality of investigations minimizes the risk
of interference and protects the identities of complainants. Indeed,
in recent investigations, employees of a Member have brought alle-
gations of misconduct to the Committee when they have remained
in the employ of the Member and faced intimidation or reprisal.13
Maintaining a confidential investigation also avoids unnecessarily
tarnishing a Members reputation before a determination of wrong-
doing has been made. As discussed further in this report, public
disclosure of an ongoing confidential Committee investigation can
also significantly impair the Committees investigation.
The fact that an investigation is conducted in a confidential man-
ner does not preclude the Committee from making a public state-
ment at the end of the investigation. For example, in this and other
recent Congresses, the Committee has issued public reports to the
House and letters of reproval in a number of investigative matters
that were initiated by the Committee and that had not previously
been publicly disclosed by the Committee.14
Whether the Committee investigates a matter under Committee
Rule 18(a) or through an ISC, by rule, the Committee may choose
to exercise its investigative authority in several different sce-
narios.15 However, most Committee investigations begin when the
Committee, on its own initiative, undertakes an investigation. In
12 The mechanism for issuing a subpoena by the Committee or an ISC does differ. Where an
ISC has been empanelled, it can authorize a subpoena, to be signed by the Committees Chair-
man and Ranking Member. If the investigation is at the Committee Rule 18(a) stage, the full
Committee can vote to issue a subpoena to be signed by the Chairman.
13 See, e.g., House Comm. on Standards of Official Conduct, In the Matter of Allegations Relat-
ing to Representative Laura Richardson, H. Rept. 112642, 112th Cong. 2d Sess. (2012).
14 See, e.g., House Comm. on Ethics, In the Matter of Allegations Relating to Representative
David McKinley, H. Rept. 114795, 114th Cong. 2d Sess. (2016); House Comm. on Ethics, In
the Matter of Allegations Relating to Representative Phil Gingrey, H. Rept. 113664, 113th Cong.
2d Sess. (2014); House Comm. on Ethics, In the Matter of Allegations Relating to Representative
Judy Chu, H. Rept. 113665, 113th Cong. 2d Sess. (2014).
15 Specifically, the Committee may exercise its investigative authority when: (1) information
offered as a complaint by a Member of the House of Representatives is transmitted directly to
the Committee; (2) information offered as a complaint by an individual not a Member of the
House is transmitted to the Committee, provided that a Member of the House certifies in writ-
ing that such Member believes the information is submitted in good faith and warrants the re-
view and consideration of the Committee; (3) the Committee, on its own initiative, undertakes
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an investigation; (4) a Member, officer, or employee is convicted in a Federal, State, or local


court of a felony; (5) the House of Representatives, by resolution, authorizes or directs the Com-
mittee to undertake an inquiry or investigation; or (6) a referral from the OCE is transmitted
to the Committee. See Committee Rule 14(a).

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14

the 114th Congress, the Committee commenced or continued inves-


tigative fact-gathering regarding 78 separate investigative matters,
most of which were begun at the Committees initiative. Those mat-
ters also included referrals from the OCE. In the 114th Congress,
the OCE referred 24 matters to the Committee, 18 with a rec-
ommendation for further review and 6 with a recommendation for
dismissal. For the six matters that OCE referred with a rec-
ommendation to the Committee that it dismiss the matter, OCE
did not provide the Committee with any Findings explaining the
recommendation, only a one-page Report with a conclusory rec-
ommendation that the matter be dismissed.
In the 114th Congress, the Committee issued letters of reproval
in two matters, one following a confidential Committee-initiated in-
vestigation under Committee Rule 18(a) that was not publicly dis-
closed until the conclusion of the investigation, and one following
an investigation conducted by an ISC following receipt of a referral
from OCE that recommended the Committee further review the al-
legations in question. Including those two matters, since 2008, the
Committee has recommended that the House issue a censure in
one matter, recommended in another matter that the House issue
a reprimand, and issued ten letters of reproval. Eight of those reso-
lutions followed investigations initiated by the Committee under its
own authority, while four of those resolutions followed rec-
ommendations by the OCE that the Committee review the allega-
tions.
The OCE is an independent office within the House created by
a House resolution in the 110th Congress after the release of a re-
port of the Democratic Members of the Special Ethics Task Force
on Ethics Enforcement (Task Force Report).16 According to the
Task Force Report, the OCE Board has the responsibility to review
information on allegations of misconduct by Members, officers, and
employees of the House and make recommendations to the Com-
mittee for the Committees official consideration and action.
Two OCE Board members may initiate a review by notifying all
other OCE Board members in writing. The OCE Board then has 30
calendar days to consider the matter in a preliminary review phase
and may vote to either terminate the review or progress to the sec-
ond-phase review. Once in the second phase, the OCE Board has
45 calendar days (with a possible one-time extension of 14 days) to
complete consideration of the matter and refer it to the Committee
with a recommendation for dismissal, further review, or as unre-
solved due to a tie vote. The OCE Boards referral may not contain
any conclusions regarding the validity of the allegations upon
which it is based or the guilt or innocence of the individual who
is the subject of the review. The Task Force believed that the
timeline requirements instituted by the new process are critical:
matters will spend at most three months under consideration by
the Board of the OCE before being referred to the Committee for
resolution. 17 The Task Force considered whether to give the OCE
either direct or indirect subpoena power. But the Task Force Re-
port ultimately decided not to give the OCE subpoena power based
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16 Special Task Force on Ethics Enforcement, 110th Cong., Report of the Democratic Members
of the Special Task Force on Ethics Enforcement (Comm. Print 2007).
17 Id. at 14. The 24 OCE referrals received by the Committee in the 114th Congress were
transmitted an average of 120 days after the start of the preliminary review phase.

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15

on a number of factors. Instead, the Task Force Report stated that


the Boards referral may include recommendations for the issuance
of subpoenas by the Committee where Members feel it appropriate.
When the Committee receives a referral from the OCE, it is re-
quired to review the referral without prejudice or presumptions as
to the merit of the allegations. 18 The Committee thus makes an
independent determination about how to proceed in the matter
based on the information before the Committee, which may include
not only the OCE referral and supporting documents provided to
the Committee by the OCE, but other information. It is not uncom-
mon that the Committees review will require more than 90 days,
because of the need to review documents, interview witnesses, and/
or assess the legal significance of evidence, among other investiga-
tive steps. Some investigations may require the review of tens of
thousands, if not hundreds of thousands, of pages of documents.
For example, in the 113th Congress one investigation that spanned
multiple Congresses required the Committee to review more than
220,000 pages of documents to resolve the matter.19
In one matter referred to the Committee during the 114th Con-
gress, although the OCE recommended dismissal, the Committee
continued review of the matter. In another matter referred during
the 114th Congress, the Committee agreed with the OCEs rec-
ommendation to dismiss certain allegations against a Member but
continued its own, confidential review of related allegations against
the same Member that were not part of the OCEs referral. As de-
scribed further below, one of those matters remains pending. Had
the Committee simply accepted the OCE recommendation to dis-
miss each matter, it would not have been required to make any
public statement or conduct any further investigation.
In some instances, the Committee may be asked to defer its in-
vestigation by another law enforcement entity, generally the U.S.
Department of Justice (DOJ). The Committee typically honors such
requests, barring unusual circumstances. For one thing, parallel in-
vestigations pose the risk of compromising one another. Also, for
the most serious criminal violations, only DOJ can pursue a pros-
ecution to seek imprisonment, the most serious possible con-
sequence for a violation of law.20 Provided that the Committee still
retains jurisdiction, a decision by the Committee to defer does not
preclude the Committee from continuing its investigation later, re-
gardless of the outcome of the other entitys investigation. In addi-
tion, a decision by the Committee to defer an investigation does not
itself indicate that any violation has occurred, or reflect any judg-
ment on behalf of the Committee. In the 114th Congress, the Com-
mittee did opt to defer several investigations at the request of DOJ,
as described further below.
The Committee publicly addressed 23 investigative matters dur-
ing the 114th Congress. In addition to confidential matters, the
Committee also carried over several public matters from the 113th
18 CommitteeRule 17A(a).
19 House
Comm. on Ethics, In the Matter of Allegations Relating to Representative Don Young,
H. Rept. 113-487, 113th Cong. 2d Sess. at 2 (2014). That investigation was begun at the Com-
mittees initiative under Committee Rule 18(a). Subsequently, the Committee established an ISC
to continue the investigation. Ultimately, the Committee issued a public report and letter of
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reproval to the Member.


20 DOJ will not lose jurisdiction to continue an investigation and pursue prosecution, if it de-
termines that is appropriate, in the event that a Member or employee leaves the House, whether
through resignation or defeat for reelection.

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Congress. In the 114th Congress, the Committee continued to ad-


dress the matters concerning Representatives Vernon G.
Buchanan, Luis Gutierrez, Cathy McMorris Rodgers, Markwayne
Mullin, Bobby Rush, Aaron Schock, and Ed Whitfield. A chrono-
logical overview of public statements made by the Committee in
the 114th Congress regarding investigative matters follows.
On March 25, 2015, the Committee unanimously voted to estab-
lish an ISC with regard to allegations that Representative Ed
Whitfield failed to prohibit lobbying contacts between his staff and
his wife, improperly used his official position for the beneficial in-
terest of himself or his wife, and dispensed special favors or privi-
leges to either his wife, the Humane Society Legislative Fund, or
the Humane Society of the United States.
On July 29, 2015, the Committee unanimously voted to establish
an ISC with regard to allegations forming the basis for criminal
charges of conspiracy, racketeering, bribery, fraud, falsification of
records, making false statements, and money laundering, as filed
against Representative Chaka Fattah in the United States District
Court for the Eastern District of Pennsylvania on July 29, 2015.
On July 31, 2015, the Committee transmitted a Report to the
House regarding allegations relating to privately-sponsored, offi-
cially-connected travel by Members and staff of the House to Azer-
baijan in May 2013.
On September 3, 2015, the Committee announced that, pursuant
to Committee Rule 18(a), it would continue to review allegations re-
ferred by the OCE that Representative Michael Honda used official
resources for campaign purposes, improperly linked official activi-
ties to campaign or political support, and used congressional staff
to assist him with personal matters.
On September 28, 2015, the Committee announced that, pursu-
ant to Committee Rule 18(a), it would continue to review allega-
tions that Representative Blake Farenthold sexually harassed a
former member of his staff, discriminated against her on the basis
of her gender, and retaliated against her for complaining about the
allegedly unlawful treatment.
On November 18, 2015, the Committee unanimously voted to es-
tablish an ISC with regard to allegations that Representative Rob-
ert Pittenger received compensation for his involvement with a fi-
duciary business, a real estate investment firm known as Pittenger
Land Investments, Inc. The Committee, following precedent, unani-
mously recommended to the ISC that it defer action on its inves-
tigation in response to a request from DOJ.
On December 14, 2015, the Committee transmitted a Report to
the House regarding allegations relating to Representative Jared
Polis.
On March 16, 2016, the Committee unanimously voted to estab-
lish an ISC with regard to allegations that Representative Corrine
Brown engaged in improper conduct relating to certain outside or-
ganizations, including allegations that she may have conspired
with other persons in connection with fraudulent activity, improp-
erly solicited charitable donations, used campaign funds for per-
sonal purposes, used official resources for impermissible non-official
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purposes, failed to comply with tax laws, and made false state-
ments, and/or failed to make required disclosures, to the House of
Representatives and Federal Election Commission. The Committee,

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17

following precedent, unanimously recommended to the Investiga-


tive Subcommittee that it defer action on its investigation in re-
sponse to a request from DOJ.
On April 5, 2016, the Committee announced that, pursuant to
Committee Rule 18(a), it would continue to review allegations re-
ferred by the OCE that Representative Alan Grayson may have
permitted the use of his name and received compensation from en-
tities providing professional services involving a fiduciary relation-
ship, agreed to receive compensation for representational services
rendered by another at a time when he was a Member of Congress
in proceedings in which the United States had a direct and sub-
stantial interest, did not report required information in his annual
financial disclosure statements, may have permitted the use of offi-
cial resources to support an outside business, held an agreement
with the United States while serving in Congress, and used official
resources for campaign purposes.
On June 24, 2016, the Committee transmitted a Report to the
House regarding allegations related to Representative Vernon G.
Buchanan.
On July 14, 2016, the Committee transmitted a Report to the
House regarding allegations relating to Representative Ed Whit-
field.
On August 11, 2016, the Committee announced that, pursuant to
Committee Rule 18(a), it would continue to review allegations re-
ferred by the OCE that Representative Roger Williams improperly
took official action on a matter in which he had a personal finan-
cial interest.
On August 17, 2016, the Committee announced that, pursuant to
Committee Rule 18(a), it would continue to review allegations re-
ferred by the OCE that Representative Mark Meadows retained an
employee who did not perform duties commensurate with the com-
pensation the employee received and certified that the compensa-
tion met applicable House standards.
On September 28, 2016, the Committee transmitted a Report to
the House regarding allegations relating to Representative David
McKinley.
On November 29, 2016, the Committee announced that, pursuant
to Committee Rule 18(a), it would continue to review allegations re-
ferred by the OCE that Representative Marlin Stutzman used cam-
paign funds for a personal purpose.
On December 15, 2016, the Committee announced that, pursuant
to House Rule XI, clause 3(b)(8)(A), and Committee Rules
17A(b)(1)(A), 17A(c)(1) and 17A(j), the Chairman and Ranking
Member of the Committee jointly decided to extend the matter re-
garding Representative Duncan Hunter, which was transmitted to
the Committee by the OCE on August 31, 2016. The Committee
stated that it would announce its course of action in this matter
following its organizational meeting and adoption of Committee
Rules in the 115th Congress.
These investigative matters are described in more detail below,
in alphabetical order. Copies of all of the Committees public state-
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ments related to these matters are included as Appendix IV to this


Report. Those statements, along with any attachments referenced
in the statements, are available on the Committees Web site. All

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18

of the Committees Reports as filed with the House are also avail-
able on the Committees Web site.
In the Matter of Allegations related to Representative Corrine
Brown
On March 16, 2016, the Committee unanimously voted to estab-
lish an Investigative Subcommittee (ISC) to determine whether
Representative Corrine Brown violated the Code of Official Conduct
or any law, rule, regulation, or other applicable standard of conduct
in the performance of her duties or the discharge of her responsibil-
ities, with respect to allegations that she engaged in improper con-
duct relating to certain outside organizations, including allegations
that she may have conspired with other persons in connection with
fraudulent activities, improperly solicited charitable donations,
used campaign funds for personal purposes, used official resources
for impermissible non-official purposes, failed to comply with tax
laws, and made false statements, and/or failed to make required
disclosures, to the House of Representatives and the Federal Elec-
tion Commission (FEC). The Committee, following precedent,
unanimously recommended to the ISC that it defer action on its in-
vestigation in response to a request from DOJ.
On July 6, 2016, the U.S. Attorney for the Middle District of
Florida filed an indictment against Representative Brown in fed-
eral district court, charging her with mail and wire fraud, con-
spiracy to commit mail and wire fraud, theft of government funds,
a scheme to conceal material facts, the corrupt endeavor to obstruct
and impede the due administration of the internal revenue laws,
and filing false federal tax returns. Proceedings in that matter are
pending in federal court.
Representative Brown lost her bid for reelection to the House for
the 115th Congress, and the Committee will not have jurisdiction
over her after January 3, 2017.
In the Matter of Allegations related to Representative Vernon G.
Buchanan
On January 27, 2012, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Vern Buchanan may have violated 18
U.S.C. 201, 1505, and 1512, as well as House Rule XXIII, clause
1, by making the settlement of a lawsuit against a former business
partner contingent on the business partner signing a false affidavit
to be filed with the FEC. The Committee in the 112th Congress re-
leased the OCE Report and Findings, along with Representative
Buchanans response, on May 9, 2012, and noted in a public state-
ment that the Committee was continuing to review the allegations
pursuant to Committee Rule 18(a).
In addition to the allegations that OCE referred to the Com-
mittee with a recommendation for further review, the Committee
also investigated allegations relating to Representative Buchanans
campaign, including whether several car dealerships partly owned
by Representative Buchanan illegally reimbursed their employees
for contributions to Representative Buchanans House campaigns,
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and whether Representative Buchanan himself may have been


aware of the unlawful reimbursements at the time they occurred,
or had some role in directing or approving them.

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These allegations were also the subject of review by the FEC and
the DOJ, and were considered by a Florida state court as part of
civil litigation involving Representative Buchanan. Much of the
material reviewed by the Committee in its investigationover
6,000 pages of documents, including statements by 22 witnesses
was generated during these parallel proceedings. The Committee
also conducted a voluntary interview with Representative
Buchanan.
On June 24, 2016, the Committee in the 114th Congress unani-
mously voted to release a Report and take no further action against
Representative Buchanan.21 In its Report, the Committee con-
cluded that there was insufficient evidence to sustain any of the
aforementioned allegations or to warrant any disciplinary action
against Representative Buchanan. Specifically, the Committee con-
cluded that three car dealerships partly owned by Representative
Buchanan did illegally reimburse their employees for contributions
to Representative Buchanans House campaigns. However, the
Committee found that the evidence was not sufficient to conclude
that Representative Buchanan himself was aware of the unlawful
reimbursements when they were made, or that he had any role in
directing or approving them. The Committee further concluded that
the evidence did not support a finding that Representative
Buchanan improperly influenced his former business partners tes-
timony before the FEC. However, the Committee did caution Rep-
resentative Buchanan to exercise more diligence over affairs re-
lated to his campaign.
In the Matter of Allegations related to Representative Blake
Farenthold
On June 29, 2015, the OCE forwarded to the Committee a Report
in which it recommended dismissal of allegations that Representa-
tive Blake Farenthold sexually harassed a former member of his
staff, discriminated against her on the basis of her gender, and re-
taliated against her for complaining about the allegedly unlawful
treatment in violation of federal law, House Rule XXIII, clause 9,
and the Congressional Accountability Act. OCE did not provide the
Committee with any Findings explaining the basis for its rec-
ommendation. The Committee released the OCE Report on Sep-
tember 28, 2015, and noted in a public statement that, although
the OCE had recommended dismissal of the matter, the Committee
was continuing to review the allegations pursuant to Committee
Rule 18(a).
As of the conclusion of the 114th Congress, the Committee had
not completed its investigation into this matter. Representative
Farenthold was reelected to the House for the 115th Congress.
In the Matter of Allegations related to Representative Chaka Fattah
On July 29, 2015, the Committee unanimously voted to empanel
an ISC to determine whether Representative Chaka Fattah vio-
lated the Code of Official Conduct or any law, rule, regulation, or
other applicable standard of conduct in the performance of his du-
ties or the discharge of his responsibilities, with respect to allega-
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21 House Comm. on Ethics, In the Matter of Allegations Relating to Representative Vernon G.


Buchanan, H. Rept. 114643, 114th Cong. 2d Sess. (2016).

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20

tions forming the basis for criminal charges of conspiracy, racket-


eering, bribery, fraud, falsification of records, making false state-
ments, and money laundering, as filed against him in the United
States District Court for the Eastern District of Pennsylvania on
July 29, 2015.
On June 21, 2016, Representative Fattah was convicted on all 23
counts in the indictment. Representative Fattah resigned from the
House on June 23, 2016. On the date of Representative Fattahs
resignation, the ISCs and the Committees jurisdiction to continue
their investigation of Representative Fattah ended.
On October 21, 2016, a federal judge upheld the conviction on
most counts, but dismissed others. Appeals in the matter are pend-
ing.
In the Matter of Allegations related to Representative Alan Grayson
On January 6, 2016, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Alan Grayson may have violated fed-
eral law, House rules, and standards of conduct when he permitted
the use of his name by, and received compensation from, entities
providing professional services involving a fiduciary relationship;
received compensation for representational services rendered by
another while he was a Member of Congress, in proceedings in
which the United States had a direct and substantial interest; did
not provide required information on his annual financial disclosure
statements; permitted the use of official resources to support an
outside business; held an agreement with the United States while
serving in Congress; and used official resources for campaign pur-
poses. The Committee released the OCE Report and Findings,
along with Representative Graysons response, on April 5, 2016,
and noted in a public statement that the Committee was con-
tinuing to review the allegations pursuant to Committee Rule
18(a).
Representative Grayson did not run for reelection to the House
for the 115th Congress, and the Committee will not have jurisdic-
tion over him after January 3, 2017.
In the Matter of Allegations related to Representative Luis V.
Gutierrez
On December 4, 2013, the OCE forwarded to the Committee in
the 113th Congress a Report and Findings in which it rec-
ommended further review of allegations that Representative Luis
V. Gutierrez impermissibly used his Members Representational Al-
lowance (MRA) to pay a consultant to perform work on behalf of
his official office. The referral also included an allegation that Rep-
resentative Gutierrez impermissibly allowed the consultant to
lobby him while the consultant was employed by Representative
Gutierrez. The Committee released the OCE Report and Findings,
along with Representative Gutierrezs response, on May 5, 2014,
and noted in a public statement that the Committee was con-
tinuing to review the allegations pursuant to Committee Rule
18(a).
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As of the conclusion of the 114th Congress, the Committee had


not completed its investigation into this matter. Representative
Gutrrez was reelected to the House for the 115th Congress.

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21

In the Matter of Allegations related to Representative Mike Honda


On June 5, 2015, the OCE forwarded to the Committee a Report
and Findings in which it recommended further review of allega-
tions that Representative Mike Honda may have used official re-
sources for campaign purposes and may have improperly linked of-
ficial activities to campaign or political support. The OCE Report
and Findings recommended dismissal of an allegation that Rep-
resentative Honda used congressional staff to assist him with per-
sonal matters. The Committee released the OCE Report and Find-
ings, along with Representative Hondas response, on September 3,
2015, and noted in a public statement that the Committee was con-
tinuing to review the allegations pursuant to Committee Rule
18(a).
Representative Honda lost his bid for reelection to the House for
the 115th Congress, and the Committee will not have jurisdiction
over him after January 3, 2017.
In the Matter of Allegations related to Representative Duncan Hun-
ter
On August 31, 2016, the OCE forwarded to the Committee a
matter involving Representative Duncan Hunter. Committee Rule
17A(j) provides that the Committee may postpone any reporting re-
quirement related to an OCE referral that falls within 60 days of
an election in which the subject of the referral is a candidate. Rep-
resentative Hunter was on the general election ballot on November
8, 2016. Therefore, the announcement that the Chairman and
Ranking Member jointly decided to extend the matter of Represent-
ative Hunter for a 45-day period, pursuant to Committee Rules
17A(b)(1)(A) and 17A(c)(1), was postponed until December 14, 2016.
On that same day, the Chairman and Ranking Member released a
public statement that the Committee would announce its course of
action in this matter following its organizational meeting and adop-
tion of Committee Rules in the 115th Congress.
As of the conclusion of the 114th Congress, the Committee had
not completed its review of OCEs referral. Representative Hunter
was reelected to the House for the 115th Congress.
In the Matter of Allegations related to Representative David McKin-
ley
On November 2, 2010, Representative David McKinley was first
elected to the House. At that time, he was the majority owner of
a West Virginia firm, McKinley & Associates (the Firm), that pro-
vided engineering and architectural services. Soon after his elec-
tion, Representative McKinley sought advice from Committee staff
regarding his ownership of, and role with, McKinley & Associates.
Staffs original advice was that the Firm would need to change its
name because architecture is a fiduciary service, and federal law
prohibits a House Member from permitting a firm which provides
fiduciary services from using the Members name.
Representative McKinley disagreed with that advice, and at-
tempted to persuade the Committee to change its position, assert-
ing that McKinley & Associates was a family name, which re-
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ferred to both himself and his father, who was a well-known engi-
neer in West Virginia. While the Committee considered Represent-
ative McKinleys request for a formal advisory opinion, he began

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22

the process of selling his interest in the Firm to the Firms Em-
ployee Stock Option Plan (ESOP), without changing the name. Rep-
resentative McKinley pursued this option based on the advice of his
counsel that selling the Firm, with the name intact, would resolve
any violations of federal law or House Rules. However, Representa-
tive McKinley did not inform the Committee of the sales process,
or ask the Committee if his counsels interpretation of the applica-
ble federal law and House Rule was correct.22 Without waiting for
the formal advisory opinion he had requested, and after receiving
notice that the opinion, when issued, would require him to change
the Firms name, Representative McKinley signed an agreement
that committed him to sell the Firm, as McKinley & Associates.
Shortly after making this agreement, on June 24, 2011, the Com-
mittee issued a formal advisory opinion to Representative McKin-
ley, stating that the Committee concluded that the Firm was
named after Representative McKinley, not his father, and that fed-
eral law and House Rules required the Firm to change its name.
After the Committee learned that Representative McKinley had
agreed to sell the Firm with his name attached, the Chairman and
Ranking Member of the Committee sent Representative McKinley
a letter on August 24, 2012, stating that the Committee expected
Representative McKinley to change the Firms name, and explain-
ing that a failure to do so could be viewed as a knowing violation
of the Ethics in Government Act (EIGA) and House Rule XXV,
clause 2, and could result in further Committee proceedings
against him. On September 14, 2012, Representative McKinley re-
sponded through counsel and stated that he had sold the Firm to
the ESOP, and that he therefore could not change the Firms name.
Due to Representative McKinleys failure to follow the Commit-
tees formal advisory opinion by changing the Firms name, the
Chairman and Ranking Member authorized staff to investigate
whether Representative McKinleys actions violated any House
rule, law, regulation, or other standard of conduct. Pursuant to this
authorization, under Committee Rule 18(a), the Committee sent
separate requests for information to Representative McKinley and
the Firm in March 2013. The Committee also interviewed relevant
witnesses, including the Firms President.
In July 2015, the Committee notified Representative McKinley
that it was considering the adoption of a public Report and Letter
of Reproval regarding this matter, and offered him the opportunity
to review the draft materials. Representative McKinley personally
reviewed the draft Report and Reproval in November 2015, and
submitted a written response, through counsel, in February 2016.
Representative McKinley appeared before the Committee in Sep-
tember 2016.23
22 The Committee determined that Representative McKinleys counsel was incorrect in his be-
lief that selling the Firm, with the McKinley name attached, would resolve the prohibition on
a Member permitting his name to be used by a firm that provides fiduciary services. In fact,
selling the Firm without requiring it to remove the Members name would actually imply such
permission.
23 Although no House or Committee Rule requires it, the Committee has generally maintained
a blackout period on public statements, including reports, in the 60 days prior to an election
in which the subject of the statement is a candidate. This is consistent with House and Com-
mittee rules regarding receipt of complaints, referrals from OCE, and certain other public state-
SSpencer on DSK4SPTVN1PROD with REPORTS

ments during this period. In June 2016, the Committee invited Representative McKinley to ap-
pear before the Committee in July 2016 to be heard in person. Representative McKinley in-
formed the Committee that he did not believe that was sufficient time for him to prepare and
asked if he could appear in September 2016, instead. The Committee granted that request, sub-

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23

Following the Committees investigation, and after hearing from


Representative McKinley in writing and in person, the Committee
determined that, by failing to remove his name from the Firm be-
fore selling it, Representative McKinley violated 5 U.S.C. app.
502, which provides that a Member shall not permit [his] name
to be used by firms providing professional services involving a fi-
duciary relationship. Representative McKinleys conduct also vio-
lated House Rule XXV, clause 2, which imposes limits on Members
outside earned income, and House Rule XXIII, clauses 1 and 2,
which state that [a] Member . . . shall behave at all times in a
manner that shall reflect creditably on the House, and shall ad-
here to the spirit and the letter of the Rules of the House. The
Committee also found that the Firm, by its continued use of the
McKinley name, could be in violation of 5 U.S.C. 501, which pro-
hibits firms that practice before federal agencies from using the
name of a Member of Congress in advertising the business. The
Committee informed the Firm of this determination, and cautioned
that it should either change the Firms name or avoid contracting
with federal agencies.
On September 28, 2016, the Committee submitted a report to the
House describing the facts and its findings in this matter and
issued a public Letter of Reproval to Representative McKinley.24
In the Matter of Allegations related to Representative Cathy McMor-
ris Rodgers
On December 23, 2013, the OCE forwarded to the Committee a
Report and Findings in which it recommended further review of al-
legations that Representative Cathy McMorris Rodgers may have
violated House rules by using House resources for campaign activ-
ity and combined campaign and House resources for her campaign
for a House leadership position. The Committee released the OCE
Report and Findings, along with Representative McMorris Rodgers
response, on March 24, 2014, and noted in a public statement that
the Committee was continuing to review the allegations pursuant
to Committee Rule 18(a).
As of the conclusion of the 114th Congress, the Committee had
not completed its investigation into this matter. Representative
McMorris Rodgers was reelected to the House for the 115th Con-
gress.
In the Matter of Allegations related to Representative Mark Mead-
ows
On March 18, 2016, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Mark Meadows violated House rules
and standards of conduct by retaining an employee who did not
perform duties commensurate with the compensation the employee
received, and by certifying that the compensation met applicable

ject to a clear written caution that if he chose that course the Committees blackout practice
would not apply to any final resolution of the matter. Representative McKinley chose to delay
his appearance until September 2016. Although he appeared before the Committee prior to the
start of the blackout period, the Committees deliberations continued into the blackout period,
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and the Committee concluded its deliberations and voted to approve the final resolution within
the blackout period.
24 House Comm. on Ethics, In the Matter of Allegations Relating to Representative David
McKinley, H. Rept. 114795, 114th Cong. 2d Sess. (2016).

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24

House standards. Committee Rule 17A(j) provides that the Com-


mittee may postpone any reporting requirement related to an OCE
referral that falls within 60 days of an election in which the subject
of the referral is a candidate. Representative Meadows was on the
primary election ballot on June 7, 2016. Therefore, the announce-
ment that the Chairman and Ranking Member jointly decided to
extend the matter of Representative Meadows for a 45-day period,
pursuant to Committee Rules 17A(b)(1)(A) and 17A(c)(1), was post-
poned until July 5, 2016. The Committee released the OCE Report
and Findings, along with Representative Meadows response, on
August 17, 2016, and noted in a public statement that the Com-
mittee was continuing to review the allegations pursuant to Com-
mittee Rule 18(a).
As of the conclusion of the 114th Congress, the Committee had
not completed its investigation into this matter. Representative
Meadows was reelected to the House for the 115th Congress.
In the Matter of Allegations related to Representative Markwayne
Mullin
On December 23, 2013, the OCE forwarded to the Committee a
Report and Findings in which it recommended further review of al-
legations that Representative Markwayne Mullin received outside
earned income in excess of the outside earned income limitations
that apply to Members of Congress, and that he impermissibly re-
ceived payment for his service on the board of directors of a com-
pany. The Committee released the OCE Report and Findings, along
with Representative Mullins response, on March 24, 2014, and
noted in a public statement that the Committee was continuing to
review the allegations pursuant to Committee Rule 18(a).
As of the conclusion of the 114th Congress, the Committee had
not completed its investigation into this matter. Representative
Mullin was reelected to the House for the 115th Congress.
In the Matter of Officially-Connected Travel by House Members to
Azerbaijan in 2013
Early in the 114th Congress, the Chairman and Ranking Mem-
ber authorized Committee staff, pursuant to Committee Rule 18(a),
to investigate allegations that several House Members and employ-
ees may have received impermissible gifts of travel and tangible
gifts in connection with privately-sponsored, officially-connected
travel to Turkey and/or Azerbaijan, in violation of Article I, Section
9, Clause 8 of the United States Constitution (the Emoluments
Clause), and various federal statutes and House rules. Prior to ac-
cepting the travel invitations, each of the House Members and em-
ployees who took part in the travel sought and obtained the Com-
mittees approval to accept the travel as privately-sponsored, offi-
cially-connected travel. Each sponsoring non-profit organization
submitted required disclosure forms to the Committee, certifying
that it was the sole sponsor of the trips, and that it had not accept-
ed direct or indirect funding for the trips from another source.
However, allegations later arose that the various non-profit spon-
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sors may have misrepresented the true source of the funds used for
the privately-sponsored, officially-connected travel, and that the
trips had not complied with the requirements for such travel.

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On January 29, 2015, the OCE notified the Committee that it


had initiated preliminary reviews of ten Members regarding their
officially-connected travel to Turkey and/or Azerbaijan. On March
2, 2015, OCE notified the Committee that it was proceeding with
a second-phase review for nine of the ten Members who were the
subject of the preliminary reviews. On March 4, 2015, the Com-
mittee voted unanimously to request that OCE cease its review and
immediately refer the matters to the Committee for its consider-
ation, pursuant to House Rule XI, clause 3(r), and Committee Rule
17A(k)(1). Though the Committees Chairman and Ranking Mem-
ber sent a letter to OCE on March 4, 2015, formally requesting
that it cease-and-refer the matters, OCE did not comply with that
request. Instead, OCE continued its review.
On May 8, 2015, the OCE forwarded to the Committee separate
Reports for nine Members who participated in privately-sponsored,
officially-connected travel to Azerbaijan in May 2013. Although
OCE is prohibited from transmitting any findings following receipt
of a cease-and-refer request from the Committee, OCE also trans-
mitted additional materials that it characterized as findings, which
recommended further review of allegations that each Member may
have received an impermissible gift of travel expenses in violation
of House rules and regulations, standards of conduct, and federal
law.25 Such a recommendation was superfluous, as the Committee
was, in fact, already investigating the allegations.26
On June 22, 2015, the Chairman and Ranking Member of the
Committee announced that the Committee had voted to extend the
Committees review of the matters referred to the Committee by
OCE. The statement by the Chairman and Ranking Member also
noted that a newspaper had obtained, and published, materials
transmitted by OCE to the Committee, without the Committees
authorization, and that the unauthorized release may have violated
House rules and other standards of conduct, while also having a di-
rect impact on the Committees investigation, which began well be-
fore OCE transmitted the materials to the Committee. As discussed
further in the Committees public report at the conclusion of the
matter, at the time of the newspapers publication of OCEs mate-
rials, the Committee had already issued a number of subpoenas to
various individuals, and had issued requests for information to a
number of entities in foreign countries.27 Discussions with all of
those parties about their cooperation with the Committees inves-
tigation were ongoing. Following the newspapers publication of the
OCE materials, a central witness in the matter invoked his Fifth
Amendment right and refused to comply with Committee sub-
poenas seeking his testimony and documents. Foreign entities out-
side of the Committees jurisdiction to compel cooperation also sub-
sequently declined to cooperate with the Committees investigation.
As such, the unauthorized disclosure of the material to the news-
25 The materials transmitted by OCE to the Committee included citations to 21 interviews of
witnesses, including the dates of those interviews. Of those 21 interviews, only 1 interview had
been conducted prior to March 4, 2015, when the Committee informed OCE that it had voted
to make a cease and refer request for these matters. House Comm. on Ethics, In the Matter
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of Officially-Connected Travel by House Members to Azerbaijan in 2013, H. Rept. 114239, 114th


Cong. 1st Sess. at 15, n.86 (2015).
26 Id. at 14.
27 Id. at 1618.

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26

paper impeded the Committees ongoing investigation, and pre-


vented it from gathering information critical to its investigation.
The June 22 public statement of the Chairman and Ranking
Member also explained that when the OCE transmits materials to
the Committee, that does not resolve the matter, as an OCE refer-
ral is only a recommendation to the Committee about whether alle-
gations in a particular matter should be investigated further or dis-
missed and an OCE referral is expressly precluded from containing
any conclusions regarding the validity of the allegations upon
which it is based or the guilt or innocence of the individual who
is the subject of a review. Ultimately, only the Committee can de-
termine whether a Member or other House employee has violated
House rules or other standards of conduct.
On July 16, 2015, the Committee sent letters to six Members
who participated in the travel, recommending that they return or
otherwise remedy certain tangible gifts they received during the
trips. All six Members complied immediately and tookor com-
mitted to takethe corrective action recommended by the Com-
mittee in its letters.
On July 29, 2015, the Committee voted unanimously to release
a Report in this matter and take no further action with respect to
any of the Members in question. Over the course of its investiga-
tion, the Committee issued 12 subpoenas and 18 voluntary re-
quests for information, interviewed ten witnesses, and collected
nearly 190,000 pages of information. In so doing, the Committee
found that the House travelers had submitted all required travel
documentation in good faith, and found no evidence that the House
travelers knew or should have known of apparent attempts by the
non-profit sponsors to obscure the true sponsors of and/or sources
of funding for the travel.
Pursuant to House Rule XI, clause 3(a)(3) and Committee Rules
7(d) and 28, the Committee voted on July 29, 2015, to refer to the
DOJ, for further action as it deemed necessary, the conduct by the
private trip sponsors detailed in the Committees Report. Pursuant
to House Rule XI, clause 3(r), the Committee also voted to publicly
release the OCE Reports as required under the cease-and-refer pro-
cedure. Because those rules only required the Committee to release
the OCE Reports, and not the materials OCE characterized as
Findings, the Committee decided to withhold public release of
any other materials to avoid interfering with any future investiga-
tion by the DOJ into possible criminal misconduct by the non-profit
sponsors and related individuals and entities outside the House.28
The Committee notes that DOJ has previously prosecuted individ-
uals referred to it by the Committee following a Committee inves-
tigation.29

28 Despite these considerations, on September 25, 2015, the OCE voted to publicly release the

OCEs Reports and the materials it characterized as Findings in this matter. The Board stated
that its action was done pursuant to House Resolution 895 of the 110th Congress 1(f)(1)(B)
(2008), which provides that the Board may release any communication pursuant to its rules
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or as necessary to conduct official business.


29 See House Comm. on Ethics, In the Matter of the Investigation into Officially Connected

Travel of House Members to Attend the Carib News Foundation Multinational Business Con-
ferences in 2007 and 2008, H. Rept. 111422, 111th Cong. 2d Sess. (2010).

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27

On July 31, 2015, the Committee submitted a Report to the


House describing the facts and its findings in this matter, as well
as its determination to take no further action in this matter.30
In the Matter of Allegations related to Representative Robert
Pittenger
On November 18, 2015, the Committee unanimously voted to
empanel an ISC with jurisdiction to determine whether Represent-
ative Pittenger violated the Code of Official Conduct or any law,
rule, regulation, or other applicable standard of conduct in the per-
formance of his duties or the discharge of his responsibilities, with
respect to allegations that he received compensation for his involve-
ment with a fiduciary business, a real estate investment firm
known as Pittenger Land Investments, Inc. The Committee, fol-
lowing precedent, unanimously recommended to the ISC that it
defer action on its investigation at that time in response to a re-
quest from DOJ.
At the conclusion of the 114th Congress, the Committee con-
tinues to defer its investigation of this matter, at the request of
DOJ. Representative Pittenger was reelected to the House for the
115th Congress.
In the Matter of Allegations related to Representative Jared Polis
On October 30, 2015, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Jared Polis may have violated House
rules, laws, and other standards of conduct by engaging in activi-
ties that could be perceived as endorsements of a video game com-
pany and a menswear company, and by using official resources to
promote the businesses.
The Committee investigated the allegations and concluded that
Representative Polis participation in a video produced by a video
game company and a clothing event with a menswear company did
not violate any law or House rules regarding official endorsements
or the use of official resources for the promotion of a business en-
deavor. Accordingly, the Committee unanimously voted to dismiss
the matter and to take no further action.
On December 15, 2015, the Committee submitted a Report to the
House of Representatives describing the facts and its findings in
this matter, as well as its determination to take no further action
in this matter.31
In the Matter of Allegations related to Representative Bobby Rush
On June 10, 2014, the OCE forwarded to the Committee a Report
and Findings in which it recommended further review of allega-
tions that Representative Bobby Rush received unpaid usage of of-
fice space. The Committee released the OCE Report and Findings,
along with Representative Rushs response, on November 10, 2014,
and noted in a public statement that the Committee was con-
tinuing to review the allegations pursuant to Committee Rule
18(a).
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30 House Comm. on Ethics, In the Matter of Officially-Connected Travel by House Members to


Azerbaijan in 2013, H. Rept. 114239, 114th Cong. 1st Sess. (2015).
31 House Comm. on Ethics, In the Matter of Allegations Relating to Representative Jared Polis,
H. Rept. 114381, 114th Cong. 1st Sess. (2015).

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28

As of the conclusion of the 114th Congress, the Committee had


not completed its investigation into this matter. Representative
Rush was reelected to the House for the 115th Congress.
In the Matter of Allegations related to Representative Aaron Schock
On August 30, 2012, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Aaron Schock may have solicited con-
tributions for an independent expenditure-only political committee
in excess of $5,000 per donor, in violation of 52 U.S.C. 30125(e),
House Rule XXIII, clause 1, and the Code of Ethics for Government
Service. The Committee released the OCE Report and Findings,
along with Representative Schocks response, on February 6, 2013,
and noted in a public statement that the Committee was con-
tinuing to review the allegations pursuant to Committee Rule
18(a).
On March 17, 2015, Representative Schock announced that he
was resigning from the House, effective March 31, 2015. On the
date of Representative Schocks resignation, the Committees juris-
diction to continue its investigation of Representative Schock
ended.
On November 10, 2016, the U.S. Attorney for the Central District
of Illinois filed an indictment against former Representative Schock
in federal district court, charging him with mail and wire fraud,
theft of government funds, making false statements, falsifying FEC
filings, and filing false federal tax returns. Proceedings in that
matter are pending in federal court.
In the Matter of Allegations related to Representative Marlin
Stutzman
On August 31, 2016, the OCE forwarded to the Committee a Re-
port and Findings in which it recommended further review of alle-
gations that Representative Marlin Stutzman may have used cam-
paign funds for personal purposes for a trip to California with his
family in violation of 52 U.S.C. 30114(b)(1) and House Rule XXIII,
clauses 6(b) and (c). The Committee released the OCE Report and
Findings, along with Representative Stutzmans response, on No-
vember 29, 2016, and noted in a public statement that the Com-
mittee was continuing to review the allegations pursuant to Com-
mittee Rule 18(a).
Representative Stutzman did not run for reelection to the House
for the 115th Congress, and the Committee will not have jurisdic-
tion over him after January 3, 2017.
In the Matter of Allegations related to Representative Ed Whitfield
On June 10, 2014, the OCE forwarded to the Committee in the
113th Congress a Report and Findings in which it recommended
further review of allegations that Representative Whitfield violated
House Rule XXV, clause 7, by failing to prohibit lobbying contacts
between his staff and his wife, who was then a registered lobbyist,
and that he dispensed special favors or privileges to either his wife
or her employers, the Humane Society of the United States or the
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Humane Society Legislative Fund. The Committee released the


OCE Report and Findings, along with Representative Whitfields
response, on November 10, 2014, and noted in a public statement

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29

that the Committee was continuing to review the allegations pursu-


ant to Committee Rule 18(a).
On March 25, 2015, based on the results of the 18(a) investiga-
tion, the Committee unanimously voted to empanel an ISC to con-
tinue to investigate the allegations in the OCE referral. Over a
thirteen month period, the ISC interviewed 11 witnesses, including
Representative Whitfield and his wife, and reviewed over 140,000
pages of documents, including Representative Whitfields own sub-
missions regarding the allegations in this matter.
On April 20, 2016, the ISC voted to adopt a Report, finding that
Representative Whitfield had violated the House Rule concerning
lobbying contacts between a Members spouse and his staff, as well
as rules regarding the dispensation of special privileges. Though
the ISC found that these violations were not intentional, it none-
theless found that Representative Whitfield failed to comprehend
the importance of setting boundaries and limits on the interactions
between his wife and his staff, and thus failed to take proper pre-
cautions to avoid either improper interactions or the appearance of
impropriety. The ISCs Report recommended that the Committee
reprove Representative Whitfield for such conduct, pursuant to
House Rule XI, clause 3(a)(2).
Pursuant to House Rule XI, clause 3(a)(2), the Committee pro-
vided Representative Whitfield with copy of the ISC Report on
April 29, 2016, and offered him an opportunity to be heard by the
full Committee. Following Representative Whitfields appearance,
and after further consideration of Representative Whitfields views
and prior written submissions, the ISC unanimously agreed to
make minor revisions to its Report, but still concluded that the vio-
lations were significant and numerous enough to warrant reproval
by the Committee. On July 6, 2016, the ISC transmitted its revised
Report to the Committee.
On July 12, 2016, the Committee considered the ISCs Report
and, agreeing with its findings and recommendations, voted unani-
mously to release its own Report, finding that Representative Whit-
field violated House Rule XXV, clause 7, the Code of Ethics for
Government Service, section 5, and House Rule XXIII, clauses 1
and 2.
On July 14, 2016, the Committee submitted a Report to the
House of Representatives describing the facts and its findings in
this matter, and adopting the ISCs Report, which served as a
reproval of Representative Whitfield.32
In the Matter of Allegations related to Representative Roger Wil-
liams
On May 13, 2016, the OCE forwarded to the Committee a Report
and Findings in which it recommended further review of allega-
tions that Representative Roger Williams may have taken an offi-
cial action on a matter affecting his personal financial interest in
an automobile dealership, by offering an amendment to certain sur-
face transportation reauthorization legislation in the 114th Con-
gress, in violation of House Rule III, clause 1, House Rule XXIII,
clause 3, and Section 5 of the Code of Ethics for Government Serv-
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32 House Comm. on Ethics, In the Matter of Allegations Relating to Representative Ed Whit-


field, H. Rept. 114687, 114th Cong. 2d Sess. (2016).

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30

ice. The Committee released the OCE Report and Findings, along
with Representative Williams response, on August 11, 2016, and
noted in a public statement that the Committee was continuing to
review the allegations pursuant to Committee Rule 18(a).
As of the conclusion of the 114th Congress, the Committee had
not completed its investigation into this matter. Representative
Williams was reelected to the House for the 115th Congress.
Other Committee investigative actions
In addition to the publicly disclosed matters discussed in this Re-
port, the Committee either commenced review of, or continued to
review from the 113th Congress, 50 investigative matters. Of these
50 matters which remain confidential, 40 were resolved in the
114th Congress.
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Insert offset folio 40 here HR910.006

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Insert offset folio 41 here HR910.007

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Insert offset folio 42 here HR910.008

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Insert offset folio 47 here HR910.013

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Insert offset folio 48 here HR910.014

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Insert offset folio 49 here HR910.015

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Insert offset folio 51 here HR910.017

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Insert offset folio 52 here HR910.018

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Insert offset folio 55 here HR910.021

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Insert offset folio 61 here HR910.027

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Insert offset folio 62 here HR910.028

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Insert offset folio 63 here HR910.029

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Insert offset folio 64 here HR910.030

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Insert offset folio 65 here HR910.031

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Insert offset folio 67 here HR910.033

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Insert offset folio 75 here HR910.041

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Insert offset folio 81 here HR910.047

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Insert offset folio 91 here HR910.057

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SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 136 here HR910.102

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00137 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
132
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 137 here HR910.103

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00138 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
133
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 138 here HR910.104

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00139 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
134
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 139 here HR910.105

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00140 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
135
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 140 here HR910.106

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00141 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
136
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 141 here HR910.107

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00142 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
137
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 142 here HR910.108

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00143 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
138
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 143 here HR910.109

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00144 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
139
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 144 here HR910.110

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00145 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
140
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 145 here HR910.111

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00146 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
141
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 146 here HR910.112

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00147 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
142
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 147 here HR910.113

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00148 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
143
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 148 here HR910.114

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00149 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
144
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 149 here HR910.115

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00150 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
145
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 150 here HR910.116

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00151 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
146
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 151 here HR910.117

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00152 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
147
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 152 here HR910.118

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00153 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
148
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 153 here HR910.119

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00154 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
149
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 154 here HR910.120

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00155 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
150
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 155 here HR910.121

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00156 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
151
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 156 here HR910.122

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00157 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
152
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 157 here HR910.123

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00158 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
153
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 158 here HR910.124

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00159 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
154
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 159 here HR910.125

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00160 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
155
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 160 here HR910.126

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00161 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
156
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 161 here HR910.127

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00162 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
157
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 162 here HR910.128

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00163 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
158
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 163 here HR910.129

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00164 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
159
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 164 here HR910.130

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00165 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
160
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 165 here HR910.131

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00166 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
161
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 166 here HR910.132

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00167 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
162
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 167 here HR910.133

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00168 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
163
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 168 here HR910.134

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00169 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
164
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 169 here HR910.135

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00170 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
165
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 170 here HR910.136

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00171 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
166
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 171 here HR910.137

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00172 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
167
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 172 here HR910.138

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00173 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
168
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 173 here HR910.139

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00174 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
169
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 174 here HR910.140

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00175 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
170
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 175 here HR910.141

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00176 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
171
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 176 here HR910.142

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00177 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
172
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 177 here HR910.143

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00178 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
173
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 178 here HR910.144

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00179 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
174
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 179 here HR910.145

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00180 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
175
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 180 here HR910.146

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00181 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
176
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 181 here HR910.147

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00182 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
177
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 182 here HR910.148

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00183 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
178
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 183 here HR910.149

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00184 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
179
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 184 here HR910.150

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00185 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
180
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 185 here HR910.151

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00186 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
181
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 186 here HR910.152

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00187 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
182
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 187 here HR910.153

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00188 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
183
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 188 here HR910.154

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00189 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
184
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 189 here HR910.155

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00190 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
185
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 190 here HR910.156

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00191 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
186
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 191 here HR910.157

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00192 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
187
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 192 here HR910.158

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00193 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
188
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 193 here HR910.159

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00194 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
189
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 194 here HR910.160

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00195 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
190
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 195 here HR910.161

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00196 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
191
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 196 here HR910.162

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00197 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
192
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 197 here HR910.163

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00198 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
193
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 198 here HR910.164

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00199 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
194
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 199 here HR910.165

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00200 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
195
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 200 here HR910.166

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00201 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
196
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 201 here HR910.167

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00202 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
197
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 202 here HR910.168

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00203 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
198
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 203 here HR910.169

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00204 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
199
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 204 here HR910.170

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00205 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
200
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 205 here HR910.171

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00206 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
201
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 206 here HR910.172

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00207 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
202
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 207 here HR910.173

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00208 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
203
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 208 here HR910.174

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00209 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910
204
SSpencer on DSK4SPTVN1PROD with REPORTS

Insert offset folio 209 here HR910.175

VerDate Sep 11 2014 23:32 Jan 19, 2017 Jkt 023224 PO 00000 Frm 00210 Fmt 6659 Sfmt 6602 E:\HR\OC\HR910.XXX HR910

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